Transcript RCRA’s Three Interrelated Programs

Range of Compliance Obligations for
Colleges & Universities
1.
Resource Conservation & Recovery Act
1. Hazardous Waste Management
1. Laboratory Chemical Wastes
2. Hazardous Drugs Wastes .
3. Operations & Maintenance
4. Student Health Drug Wastes
2. Universal Wastes
3. Underground Storage Tank Standards
4. Emergency Preparedness & Community Right to Know
5. Federal Insecticide, Fungicide & Rodenticide Act
6. Toxic Substances Control Act
> Import/Export Notification
> Preserving Laboratory Exemptions
> PCBs in Equipment
2.
Clean Air Act
1. Title V Permit Compliance
1. Steam Plant Permit Compliance
2. Emergency Generators
3. Ethylene Oxide Sterilizers
4. Small Animal Incinerator
2. Section 112r Risk Management Planning
3. Stratospheric Ozone Protection
4. State Permits to Construct and Operate
3.
Clean Water Act
1. Spill Prevention Control and Countermeasure Plans
2. Stromwater Management Permits
3. Discharges to local POTW and Pretreatment
Emergence of Regulations to Manage
Hazardous Wastes
• Growing awareness of the impact and
magnitude of abandoned waste sites on the
environment and human health (Love Canal).
• The exponential growth of manufactured
chemicals entering the environment.
The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as
Superfund was enacted by Congress on December 11, 1980. This law created a tax on the chemical and petroleum
industries and provided broad Federal authority to respond directly to releases or threatened releases of hazardous
substances that may endanger public health or the environment. CERCLA:
 established prohibitions and requirements concerning closed and abandoned hazardous waste sites;
 provided for liability of persons responsible for releases of hazardous waste at these sites; and
 established a trust fund to provide for cleanup when no responsible party could be identified.
The law authorizes two kinds of response actions:
Short-term removal actions, where actions may be taken to address releases or threatened releases requiring
prompt response.
Long-term remedial response actions, that permanently and significantly reduce the dangers associated with
releases or threats of releases of hazardous substances that are serious, but not immediately life threatening.
Resource Conservation and Recovery Act
The Resource Conservation and Recovery Act (RCRA) of 1976 was the first
substantial effort by Congress to establish a regulatory structure for the management
of solid and hazardous wastes.

Subtitle C of RCRA addresses "cradle-to-grave" requirements for hazardous
waste from the point of generation to disposal.

Subtitle D of RCRA contains less restrictive requirements for non-hazardous
solid waste.
RCRA – Cradle to Grave Waste Management
Resource Conservation and Recovery Act -1976
•
•
•
•
A cradle-to-grave system to track
and monitor hazardous waste
Established management
standards for anyone who
generates, recycles, transports,
treats, stores, or disposes of
hazardous waste.
Authorized States to implement
RCRA programs equal to or more
stringent than federal program.
Goals –
– Ensure that wastes are managed
in manner that protects human
health and the environment
– Reduce/eliminate the amount of
waste generated, including
hazardous wastes
– Conserve energy and natural
resources through waste recycling
and recovery.
•
•
•
•
Banned open dumping
Provided a comprehensive
national program to encourage
source reduction, recycling, and
safe disposal of solid waste.
Mandated strict requirements for
treatment, storage, and disposal
of hazardous waste to minimize
present and future risks.
First hazardous waste facility
permit was issued in October,
1981.
RCRA’s Three Interrelated Programs
Subtitle D
Subtitle C
Subtitle I
Solid Waste
Management
Hazardous
Waste
Management
Underground
Storage Tank
Program
RCRA Hazardous Waste Management
Scheme
• Hazardous Waste
Identification
• Hazardous Waste
Recycling and Universal
Wastes
• Standards Governing
Hazardous Waste
Generators
• Standards Governing
Transporters
• Standards Governing
Treatment, Storage and
Disposal
• Land Disposal
Restrictions
•
•
•
•
•
Hazardous Waste
Combustion
Permitting of TSD
Facilities
Corrective Action to
Clean Up Hazardous
Waste
Enforcement of
Regulations
Authorization of State
Programs
A Hazardous Waste is:
A "solid waste" which because of its quantity,
concentration, or physical, chemical, or infectious
characteristics may:
– Pose a substantial present or potential hazard to human health or
the environment when improperly treated, stored or disposed of,
or otherwise mismanaged; or
– Cause or contribute to an increase in mortality, or an increase in
irreversible or incapacitating illness.
Defining Hazardous Waste
• Is the material a solid
waste?
– Recycled materials
– Secondary materials
• Excluded wastes
–
–
–
–
Some solid wastes
Exempt hazardous wastes
Raw or process wastes
Waste samples
• Is the waste a listed
hazardous waste?
– Listed hazardous wastes
– Waste listed due to certain
characteristics
• Hazardous Waste
Characteristics
–
–
–
–
Ignitibility
Corrosivity
Reactivity
Toxicity
• Special Wastes
– Mixtures
– Derived-from rule wastes
– Contained-in rule wastes
RCRA Hazardous Waste Management
Scheme
• Hazardous Waste
Identification
• Hazardous Waste
Recycling and Universal
Wastes
• Standards Governing
Hazardous Waste
Generators
• Standards Governing
Transporters
• Standards Governing
Treatment, Storage and
Disposal
• Land Disposal
Restrictions
•
•
•
•
•
Hazardous Waste
Combustion
Permitting of TSD
Facilities
Corrective Action to
Clean Up Hazardous
Waste
Enforcement of
Regulations
Authorization of State
Programs
Requirements for Hazardous Waste
Generators
Regulated generators
– Large Quantity
– Small Quantity
– Conditionally Exempt
Waste identification
Registration & ID number
Accumulation times
Preparation of waste for transport
Waste manifests
Recordkeeping and reporting
Emergency procedures and
Contingency planning
Personnel training
RCRA Hazardous Waste Management
Scheme
• Hazardous Waste
Identification
• Hazardous Waste
Recycling and Universal
Wastes
• Standards Governing
Hazardous Waste
Generators
• Standards Governing
Transporters
• Standards Governing
Treatment, Storage and
Disposal
• Land Disposal
Restrictions
•
•
•
•
•
Hazardous Waste
Combustion
Permitting of TSD
Facilities
Corrective Action to
Clean Up Hazardous
Waste
Enforcement of
Regulations
Authorization of State
Programs
Hazardous Waste Treatment
•
•
•
•
Oxidation – Strong oxidizing
agents breakdown hazardous
wastes into less toxic or less
mobile constituents.
Deactivation – A process that
removes the hazardous nature of
waste by neutralizing
characteristics such as ignitibility,
corrosivity, or reactivity.
Incineration – High temperature
oxidation of waste, usually at
temperatures ranging from 1600
to 2500 F.
Industrial Furnace – Uses thermal
energy to recover energy or
materials. Includes cement kilns,
lime kilns, coke ovens, blast
furnaces, and smelting furnaces.
•
•
•
•
Micro-encapsulation – A process
that coats the surface of the waste
material with a thin layer of plastic
or resin to prevent leaching.
Neutralization – A process used to
treat corrosive hazardous waste
streams.
Stabilization – A process that
reduces the mobility of hazardous
waste constituents.
Treatment in Tanks – Mechanical
settling, gravity settling, or
chemical oxidation to remove
hazardous constituents.
Hazardous Waste Treatment & Disposal
Standards
•
•
•
•
•
•
Permits to Operate
Performance Standards
Recordkeeping & Reporting Requirements
Groundwater Protection
Corrective Action
Emergency Preparedness & Contingency
Planning
Some Cases • Laboratory Waste Management
• Healthcare Compliance Initiative
• Regulated electronic wastes
Managing Waste Chemicals
Management of Waste Chemicals Generated in Laboratories
Large Quantity Generator
Waste Management
Standards –
Part 262 RCRA
Labs can be subject to
Satellite Accumulation
Standards – Part 262.34
Best Management
Practices –
HHMI Proposal
Distribution of Wastes Shipped to TSDF – 524,352 lbs Collected
Defining Hazardous Waste Management
in Academic Laboratories
•
Project XL – New England Laboratory
Project –
–
•
•
Evaluated flexible application of
generator rules to academic research
laboratories.
HHMI Report to Congress – October
2001 –
–
Proposed a set of best practices for the
management of laboratory wastes.
Nat’l Assoc. of College and University
Business Officers – March 2002 –
Environmental Excellence in Higher
Education
–
•
Addressed the application of waste
management regulations to the activities
of colleges and universities.
US EPA Notice for Information on the
Effectiveness of RCRA Generator
Program and Areas for Improvement –
October 2003.
–
•
Meeting of agencies and stakeholders on
rules flexibility
US EPA Memorandum – March 2004 –
–
Clarification regarding satellite accumulation
practices.
•
US EPA Notice Concerning hazardous
waste generator program – April, 2004.
•
US EPA Final Rule – Standards
Applicable to Generators of Hazardous
Waste; Subpart K – Academic and
Research Laboratories – December
2008.
Subpart K Changes
1.
Container Labeling –
1.
2.
3.
2.
Chemicals, products of experiments or other materials no
longer needed can be labeled as “unwanted materials.
The label must contain a general description of the
contents and sufficient information to alert emergency
responders.
The date of initial accumulation in a container must be
recorded.
Accumulation Time in the Laboratory –
Unwanted materials must be removed once every six
months or whenever 55 gallons is accumulated.
3.
Point of Hazardous Waste Determination –
1.
2.
4.
Waste determinations must be made by a “trained
professional”
Unwanted material moved to an on-site central
accumulation area must be identified as hazardous waste
within 4 days.
Laboratory Management Plan (LMP)
Emerging Issues • Healthcare Compliance
– Hazardous Drugs Disposal
– Chemotherapeutics
• Electronic Wastes
What’s Regulated as a
Hazardous Waste?
•
•
•
•
Certain chemotherapeutic drugs
Drugs that are “listed hazardous waste”
Drugs that are “characteristic waste”
Containers that held regulated drugs
Duke Hospitals Formulary
PharmE® Inventory Analysis
Summary of Results
Fed Haz, 315, 3%
Non Hazardous,
8316, 86%
Fed Haz
PharmE Hazardous
Non Hazardous
PharmE Hazardous,
1005, 11%
Hospital Waste Streams
Hazardous
Pharmaceutical
waste (15%)
Non-hazardous
pharmaceutical waste
(~ 85%)
All waste pharmaceuticals
in inventory not identified
as hazardous
RCRA Waste (5%)
P-listed waste
U-listed waste
D-listed waste
> Ignitable waste
> Toxic waste
> Corrosive waste
> Oxidizers
Chemo spill materials
RCRA listed chemo
agents
(residues & bulk)
Non-empty > vials, syringes, IVs
Sharps and RMW
Empty/trace
vials, syringes,
IV bags
Non-RCRA Waste (~ 10%)
Non-listed chemotherapeutics
NIOSH hazardous drugs
Carcinogens
Endocrine disruptors
Toxic drugs – LD50 < 50 mg/kg
Formulations containing listed
waste not the sole active ingredient
Blue
bin
Trace
chemotherapeutic
waste
RMV Red or
Sharps Box
Gowns, gloves,
goggles, tubing,
wipes
Waste Management
Process Proposal
Municipal
Waste
Sewer
System
Pharmaceutical
Waste -
Regulated
medical waste
Non-Hazardous
Waste
(85%)
Hazardous Waste
(15%)
Hazardous Waste
Container
Recycle as much
paper, glass,
plastic as
possible
RCRA Hazardous
Waste
Check with local
wastewater
treatment plant for
limits, etc.
Sharps
Container
Bio-Red Bag
waste container
Collect & Segregate
FEDERALLY PERMITTED
HAZARDOUS WASTE
INCINERATOR (HIGH
TEMPERATURE)
Non- RCRA
hazardous
drugs
Waste to Energy
TREATMENT FACILITY
RESIDUE TO LINED HAZARDOUS
WASTE LANDFILL
Sharps
REGULATED MEDICAL
WASTE INCINERATOR
RESIDUE TO NON-HAZARDOUS
WASTE LANDFILL